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Data Protection and Privacy Policy

Overview

Ferguson Partners L.P., Ferguson Partners Europe Ltd, the Japan branch of Ferguson Partners Europe Ltd, Ferguson Partners Hong Kong Limited, Ferguson Partners Singapore Pte. Ltd., Ferguson Partners Canada Co., FPL Associates L.P., FPL Corporate Services LLC and FPL Advisory Group Holdings LLC (collectively, “FPL,” “we” or “us”) are serious about protecting your privacy. We understand your concerns with regard to how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This notice (this “Privacy Policy”) describes what information we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it. This Privacy Policy is incorporated into and is a part of the Terms & Conditions of the FPL Web site (www.fpladvisorygroup.com, www.fergusonpartners.com , www.fplassociates.com , or any replacement site, the “Site”). We encourage you to become familiar with the terms and conditions of both this Privacy Policy and the Terms & Conditions. By accessing and using the Site, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy. If you provide us with any identifiable information about any other persons in the context of surveys or otherwise, you agree that you have notified such persons and obtained any necessary consents for the processing of such data in accordance with this Privacy Policy.

What Information Do We Collect?

We may collect certain identifying information from or about you (and organizations with which you are affiliated, hereinafter “your company”) in connection with your use of the Site or submissions to FPL, whether through the Site or through other communications that you or your company may have with us, including any survey or interview responses and other data provided by you or your company (collectively, “Collected Information”). Collected Information may include, but is not limited to, your name, street address, telephone number, email address, educational background, employment history, overall compensation, information on your resume or CV, your job responsibilities and reporting requirements, personal performance and company objectives, information about short- and long-term incentive programs, benefits information, opinions on the strengths and weaknesses of your company, competitors in the market, the current compensation program, and any other information submitted by you or your company. In addition, we may retain the content of, and metadata regarding, any correspondence and other communications that you may have with us or our representatives, regardless of the mode of communication by which such correspondence was made. This information helps us to improve the Site and the online media, content, materials, opportunities, and services that we feature or describe on the Site, and to more effectively and efficiently respond to both current and future inquiries. It is voluntary for you to provide us with your personal data, but if you choose not to provide us with certain data we may not be able to offer you certain services.

As with many other Web sites, the Web servers used to operate the Site and related emails that we send may collect certain data pertaining to you and the equipment and communications method that you use to access the Internet and the Site. For security reasons and to confirm the integrity of our surveys, FPL may combine components of this data with other sources of information which may identify you. Unless otherwise described in this Privacy Policy or our Terms & Conditions, this identifying information will be used solely for internal business purposes. In addition, such information does reveal such things as the Internet protocol (“IP”) address assigned to your computer, specific pages that you accessed on the Site, or immediately prior to visiting the Site, and the length of time you spent at the Site. If you are receiving communications such as emails or newsletters that we may periodically post, publish, or distribute, we may also collect information regarding when you received, opened, reviewed and responded to such emails or other communications that we sent to you. The purposes for which this information is collected and used include facilitating Site operation and system administration, generating aggregate, non-identifiable statistical information, monitoring and analyzing Site traffic and usage patterns, and improving the content and content delivery with regard to the Site, emails, and the online media, content, materials, opportunities, and services that we describe or make available on the Site.

We may also use “cookies” to track your online activities and to customize your access and use of the Site, in accordance with applicable law. Cookies are small text files placed on your computer by a website server which help a website recognize a particular user when he or she returns to the website following a previous visit. Your web browser may be set to accept cookies automatically, but can be changed to decline them. The Help section of the toolbar on most browsers will tell you how to set your browser to prevent accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether. Please note that if you decline to accept cookies, you may be prevented from taking full advantage of the Site and its capabilities.

How Do We Use The Information That We Collect?

In addition to the uses mentioned or described above, or otherwise described in our Terms & Conditions, we may use the information that we collect from or about you for certain purposes that are relevant to our relationship with you, your company and/or our clients, such as: to analyze and improve the content, features, materials and opportunities that we make available on the Site or through other communications with you; to notify you of changes made to the Site or new opportunities made available on or through the Site or from FPL; to evaluate your needs and customize the Site content delivered to you according to those needs; to conduct compensation studies, surveys, and other research; to prepare analysis and provide compensation, leadership, organizational structure, strategic planning and other consulting and advisory services; to provide recruitment and executive, director, and professional search services; to provide you with information and updates about our services, new offerings and events; and for other legitimate and lawful business purposes. FPL Advisory Group retains your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) will remain valid after termination of our relationship with you. If you contact us for support or assistance, we may use information about you or your system for purposes such as verifying whether your system meets the minimum requirements needed to use the Site and our various services.

With Whom Do We Share Information That We Collect?

In addition to the uses mentioned or described above, or otherwise described in our Terms & Conditions, in the course of analyzing survey results or otherwise conducting our business, we may share the Collected Information about you or your company with any of the FPL Advisory Group companies listed above. We may also catalog and add such Collected Information to our database, and provide such Collected Information to our clients and contractors, subject to applicable law and with your consent where legally required, for purposes related to conducting our business and providing you with our services. The business operator responsible for the management of the Collected Information is FPL Corporate Services LLC, which can be contacted through the contact details listed below.

We utilize a number of trusted business and marketing partners in delivering the online media, content, materials, and opportunities available on or through the Site to you. To the extent necessary for purposes of communicating with you, or fulfilling your requests for our products, services, content, and materials, we may provide information about you to these business partners or service providers. Please rest assured, however, that except for the specific uses described in this Privacy Policy or in our Terms & Conditions, any Collected Information that we obtain will be reported outside our organization only in aggregated formats, and we will not distribute any Collected Information in a manner that will identify or be attributable to any named individual or company.

We may produce reports on Site traffic or usage patterns and share these reports with our business partners and others, but the information contained in these reports is anonymous and does not allow identification of any specific individual.

We may disclose information about you if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose information about you to establish or exercise our legal rights, to enforce the Terms & Conditions, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person, to the extent permitted by applicable law.

As FPL continues to grow and develop its business, it is possible that its corporate structure might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, Collected Information generally is, will most probably be, and should be expected to be one of the transferred business assets.

What Choices Do You Have?

You may elect at any time to opt-out of receiving emails and newsletters that we may periodically post, publish or distribute. Except for information collected by automated means, when corresponding with FPL or our representatives, or when making a request for information or otherwise interacting with FPL or others through the Site, you choose what information to supply, what questions to pose and comments to make, whether you wish to receive further information, and by what method of communication such information should be delivered. Please take care to share only such information as is needed or that you believe is appropriate.

How Do We Protect Information Collected About You?

FPL takes commercially reasonable measures to secure and protect information transmitted via or stored on the Site. Nevertheless, communications over the Internet are not totally secure, and no security system is impenetrable. We cannot and do not guarantee that any communications or any electronic commerce conducted on or through the Site, or that any information that you submit or that we collect, in connection with the Site or otherwise, will be totally secure. You agree to immediately notify us of any breach of Site security, or of this Privacy Policy or the Terms and Conditions of which you become aware.

How Do We Process Information Collected About Non-US Residents?

If you are a resident of a non-US jurisdiction, such as the United Kingdom, Canada, Hong Kong, Japan or Singapore, we generally process and protect information about you in the same manner as otherwise described in this Privacy Policy. You should note that we are a US-headquartered organization; our operations as well as the servers that support this Site are located in the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws in your home country. In addition, if you would like to request access to, or correction of, your own personal data, or otherwise seek to exercise any specific rights you may have under applicable data protection laws, please contact us at:

FPL Corporate Services LLC
Chief Administrative Officer
123 North Wacker Drive, Suite 1900
Chicago, Illinois 60606
Telephone: (312) 368-0569

or at the following email address:
privacy@fpladvisorygroup.com

or in Hong Kong at the following address:
Ferguson Partners Hong Kong
Level 17, China Building
29 Queens Road, Central
Hong Kong

Linked Sites

For your convenience, some hyperlinks may be posted on the Site that link to other Web sites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We encourage you to seek out and read the privacy policy of each Web site that you visit. In addition, should you happen to initiate a transaction on a Web site that our Site links to, even if you reached that site through our Site, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked site. You should read that site’s privacy policies to understand how personal information that is collected about you is used and protected.

Changes to Privacy Policy

From time to time, we may change our privacy practices, and this Privacy Policy, because of changes in relevant and applicable legal or regulatory requirements, our business practices, or in our attempts to better serve your needs and those of our other customers. Notice of such changes to our privacy practices will be given in the manner described in the Terms & Conditions and a revised Privacy Policy will be posted on the Site.

Who Can You Contact For More Information?

If you have any questions or suggestions about the Site, FPL, or our products, services, or privacy practices, or you wish to request disclosure, correction, addition to, deletion of, erasure or discontinuance of use retained personal data, please contact us at the number or address given below.

FPL Corporate Services LLC
Chief Administrative Officer
123 North Wacker Drive, Suite 1900
Chicago, Illinois 60606
Telephone: (312) 368-0569
or at the following email address: privacy@fpladvisorygroup.com .

This Privacy Policy is effective as of: February 4, 2014.

Acknowledgement

BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND CONSENT TO THE PRIVACY PRACTICES, AND TO THE USES, TRANSFERS (LOCAL AND OVERSEAS/INTERNATIONAL) AND DISCLOSURES OF COLLECTED INFORMATION, THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND YOU AGREE TO BE BOUND BY THE TERMS & CONDITIONS REFERENCED ABOVE.

 
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